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Privacy Policy

Privacy Policy

This Privacy Policy sets the rules for storing and accessing data on Users’ Devices who use the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing personal data of Users, which have been provided by them personally and voluntarily through tools available in the Service.

§1 Definitions

  • Service – the “dotGrow” online service operating at https://dotgrow.net.
  • External Service – online services of partners, service providers, or contractors cooperating with the Administrator.
  • Service/Data Administrator – the Service Administrator and the Data Administrator (hereinafter referred to as the Administrator) is the company “dotGrow Daniel Andraszewski”, operating at: ul. Korzona 113/71, Warsaw, 03-571 Poland, with the tax identification number (VAT ID): PL5242679498, providing electronic services via the Service.
  • User – an individual for whom the Administrator provides services electronically via the Service.
  • Device – an electronic device with software through which the User gains access to the Service.
  • Cookies – text data collected in the form of files placed on the User’s Device.
  • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).
  • Personal Data – means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific factors related to physical, physiological, genetic, mental, economic, cultural, or social identity.
  • Processing – means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collecting, recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.
  • Restriction of processing – means the marking of stored personal data to limit their future processing.
  • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, particularly to analyse or predict aspects concerning the performance, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements of that individual.
  • Consent – consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
  • Pseudonymisation – means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  • Anonymisation – anonymisation of data is an irreversible process of operations on data that destroys or overwrites “personal data” making it impossible to identify or link a record with a specific user or natural person.

§2 Data Protection Officer

Pursuant to Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer. For matters concerning the processing of data, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal Cookies – files placed and read from the User’s Device by the Service’s telecommunication system.
  • External Cookies – files placed and read from the User’s Device by telecommunication systems of External Services. The scripts of External Services that may place Cookies on the User’s Device have been intentionally embedded in the Service through scripts and services made available and installed in the Service.
  • Session Cookies – files placed and read from the User’s Device by the Service during a single session of the Device. After the session ends, the files are deleted from the User’s Device.
  • Persistent Cookies – files placed and read from the User’s Device by the Service until they are manually deleted. These files are not deleted automatically after the Device’s session ends unless the User’s Device configuration is set to remove Cookies after the session ends.

§4 Data Storage Security

  • Mechanisms for storing and reading Cookie files – The mechanisms for storing, reading, and exchanging data between Cookie files saved on the User’s Device and the Service are implemented through built-in mechanisms of web browsers and do not allow the retrieval of other data from the User’s Device or data from other websites that the User has visited, including personal data or confidential information. Transferring viruses, trojans, or other worms to the User’s Device is also practically impossible.
  • Internal Cookies – Cookies used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that could endanger the security of personal data or the security of the Device used by the User.
  • External Cookies – The Administrator takes all possible measures to verify and select service partners in the context of Users’ security. The Administrator cooperates with reputable, well-known partners of global trust. However, the Administrator does not have full control over the content of Cookies from external partners. Therefore, as much as the law allows, the Administrator is not responsible for the security, content, or lawful use of Cookies from External Services installed through scripts embedded in the Service.
  • Control of Cookie Files – Users can, at any time, independently change their settings for saving, deleting, and accessing the data saved in Cookie files by each website. Instructions on how to disable Cookies in the most popular desktop browsers are available on the following sites:
  • User Side Risks – The Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that the security of these data depends on both sides, including the User’s activities. The Administrator is not responsible for interception, session impersonation, or deletion of these data as a result of intentional or unintentional User activity, viruses, trojans, or other spyware that may or has infected the User’s Device. To secure against these threats, Users should follow the guidelines for safe Internet usage.
  • Personal Data Storage – The Administrator ensures that every effort is made to keep personal data voluntarily entered by Users secure, restrict access, and process it in line with its intended purpose. The Administrator also ensures every effort to secure stored data from loss through the application of appropriate physical and organisational safeguards.

§5 Purposes for Which Cookies Are Used

  • Enhancing and facilitating access to the Service
  • Personalising the Service for Users
  • Marketing and remarketing on external platforms
  • Advertising services
  • Affiliate services
  • Conducting statistics (user counts, number of visits, types of devices, connections, etc.)
  • Providing multimedia services
  • Offering social networking services

§6 Purposes of Personal Data Processing

Personal data provided by Users is processed for the following purposes:

  • Providing online services:
    • Responding to enquiries submitted through the contact form.
    • Enabling information about content on the Website to be shared through social media or other websites.
    • Receiving requests for, preparing and delivering reports, analyses and other resources requested through the Website.
  • Sending marketing emails about the Administrator’s services and offers based on the recipient’s consent.
  • Managing enquiries and business relationships through the CRM system.
  • Protecting forms against misuse, spam and automated submissions.
  • Communicating with Users about the Website and data protection.
  • Pursuing the Administrator’s legitimate interests.

Information about Website use, including automatically collected data, may be processed for website statistics, remarketing, personalised advertising (subject to the required consents), affiliate programme management and the Administrator’s legitimate interests.

§7 Cookies from External Services

The Administrator uses JavaScript scripts and web components from partners on the Service, who may place their own cookies on the User’s Device. Below is a list of partners or their services implemented on the Service that may place cookies:

§8 Types of Data Collected

The Website may automatically collect technical and usage information, some of which may constitute personal data:

  • IP address, browser type, screen resolution, approximate location, pages visited, time spent on the Website, operating system, referring page, browser language, connection details and, depending on the tools used, demographic information.

Data collected when subscribing to the Newsletter:

  • Name or pseudonym, email address and IP address (collected automatically).

Data processed when requesting resources:

When you request reports, analyses or other resources through the Website, we may process:

  • Your email address.
  • Information submitted through the form, including a website address where required to prepare the requested resource.
  • Your IP address and technical information needed to protect the form against misuse.
  • Information about the resource requested and your selected language.

The relevant form specifies which information and consents are required. For certain free resources, agreeing to receive marketing emails is also a condition of submitting a request.

We may use publicly available information about websites, brands and businesses to prepare reports and analyses.

Access to resources:

Some resources, particularly individual reports, may be available through unique web addresses without requiring you to sign in. These pages may use a noindex directive to discourage search engines from indexing them. However, this does not make a resource confidential: anyone with the link can access it.

When such resources are viewed, their URLs may also be processed by analytics providers used on our Website, subject to applicable consent settings.

§9 Access to Personal Data by Third Parties

The Administrator may share personal data with service providers that process it on the Administrator’s behalf, to the extent necessary to provide their services.

We use our own systems to manage requests and prepare resources, including Monai for producing reports and analyses and an internal CRM system for managing business contacts.

External service providers include:

§10 Method of Processing Personal Data

  • Personal data is primarily processed within the European Economic Area (EEA), including Poland, where the Administrator is established. Some international service providers may also process data outside the EEA, including in the United States.
  • Where personal data is transferred outside the EEA, appropriate safeguards are applied, depending on the recipient and destination, such as relevant adequacy decisions (including the EU–US Data Privacy Framework where the recipient is certified) or Standard Contractual Clauses. Where the UK GDPR applies, relevant UK international transfer requirements are also taken into account.
  • Personal data will not be used to make solely automated decisions about Users that produce legal or similarly significant effects.
  • Personal data will not be sold to third parties.

The Website collects and processes Users’ data under:

  • Regulation (EU) 2016/679 (EU GDPR), Article 6(1)(a) (consent), (b) (performance of a contract or pre-contractual steps) and (f) (legitimate interests).
  • The Polish Act of 10 May 2018 on the Protection of Personal Data.

When you request resources or submit an enquiry:

  • Preparing and delivering requested resources: your consent under Article 6(1)(a) of the EU GDPR or UK GDPR, as applicable.
  • Sending marketing emails: your consent under Article 6(1)(a) of the applicable data protection legislation, together with relevant electronic marketing rules, including the Polish Electronic Communications Law (Article 398) and the UK’s Privacy and Electronic Communications Regulations (PECR), where applicable.
  • Managing enquiries and business contacts through our CRM: our legitimate interests in managing business relationships under Article 6(1)(f) of the applicable data protection legislation.
  • Protecting forms and the Website against misuse: our legitimate interests in maintaining the security of our services under Article 6(1)(f) of the applicable data protection legislation.

You may withdraw your consent at any time by contacting us using the details in §14. Withdrawal does not affect the lawfulness of processing carried out before your consent was withdrawn.

You also have the right to object to processing based on our legitimate interests, including processing for direct marketing purposes.

§12 Duration of Processing Personal Data

We generally retain personal data only for as long as necessary for the purpose for which it was collected, subject to applicable legal requirements and the exceptions below.

We retain personal data relating to requests and resources for the following periods:

  • Information submitted through forms: for as long as necessary to handle the request and provide the requested service or resource.
  • Individual reports and their URLs: for up to 12 months after publication, unless earlier deletion is required.
  • Contact details and communication history in our CRM: until you withdraw your marketing consent or successfully object to the relevant processing, and no longer than three years after our last contact, unless another lawful basis justifies further retention.
  • Technical data used for security purposes: for as long as necessary to prevent misuse and investigate security incidents.

We may retain information for longer where required by law or where necessary to establish, exercise or defend legal claims.

Subject to applicable law, you have the right to access and rectify your personal data, request its erasure or restriction, receive your data in a portable format and object to its processing.

You may lodge a complaint with the Polish Personal Data Protection Office (UODO). Where the UK GDPR applies, you may also have the right to complain to the UK’s Information Commissioner’s Office (ICO).

§14 Contacting the Administrator

You can contact the Administrator in one of the following ways:

§15 Service Requirements

Limiting cookies may cause some functions of the Service to malfunction. The Administrator is not responsible for such malfunctioning features.

The Service may contain links to external websites. The Administrator is not responsible for the content or security of those sites.

§17 Changes to the Privacy Policy

The Administrator reserves the right to change this Privacy Policy at any time. Changes will be published on this subpage and come into effect upon publication.